Conclusions and major achievements of initial iteration
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The pilot has arrived at the starting point of actually piloting with real life participants. Pilot partners managed to analyse the most important challenges for the implementation of the SDGR (like record matching, evidence-definition and powers validation), and developed an international infrastructure for cross-border exchange of company evidence, by deploying and integrating DE4A common components to business registers and service providers. Also, a cross-border authentication and powers validation infrastructure for piloting was established, using eIDAS pilot nodes. This infrastructure was designed, implemented and extensively tested until the point where the operation of the infrastructure was considered proven, and reliable to facilitate real-life piloting. It supports the exchange of harmonized datasets about company-registrations, while the designs and assessments have been completed to extend the infrastructure for cross-border notifications about changes in company-registrations. The infrastructure established for the first iteration of the pilot, is expected to provide a good starting point for these extensions.
The exercise of analyzing, developing and testing the infrastructure as well as all legal and organizational preparation lead to the conclusion that the DE4A common components have proven to be deployable and can be integrated to national infrastructures. All DBA partners managed to do so without running into any unexpected major technical or legal difficulties. Experienced delays originated in the complex and innovative nature of the project which takes more time than expected, as wel as in prioritization challenges within Member States.
Based on structured tests and analysis, the intermediation pattern has proven useful for the business procedures as defined in the SDG Annex 2. The need for receiving notifications about changes in business register entries was validated during analysis and design, regarding both changes in company data and company-concerned events. Analysis shows that this need cannot fully be fulfilled by BRIS. For the DBA pilot, a small set of events and changes has been selected for piloting, using the Subscription and Notification pattern.
The availability of a EU-wide operational eIDAS network and notified eID's for representing companies (including powers validation) are prerequisites for implementing the SDG. As almost none of the Member States have notified eIDs for companies, temporary use of non-notified eIDAS were allowed for piloting the DBA procedures. Using company identifiers from national business registers as eIDASLegalPersonIdentifier, solves the quest for record matching on company level at the Data Provider. Regarding the check on mandates of representatives, fine grained powers validation should be the goal and SEMPER specifications match the requirements for this goal. Starting with a simpler full-powers validation turns out to be a feasible and useful first step.
Member States establish their own maximum velocity for implementing the necessary infrastructural, legal and procedural changes. Velocities differ between Member States because each Member State has a different starting point and therefore faces different challenges. Establishing coordination on Member State level for SDG implementation activities proves to be an important factor for success . An European strategy to implement the SDG should allow for individual national timelines, while still having all Member States converge to a clear endpoint in time in order to secure progress and make sure that the solution will become available for European Citizens and companies. Applying a general step-by-step strategy for implementing the SDG infrastructure, very gradually increasing complexity, has proven to help with focus and management of the implementation.
Establishing a harmonized dataset that embodies the evidence to be exchanged cros- border turns out to be time-consuming. Having the evidence match the needs of Data Evaluators and making sure that this van be provided by Data Owners requires much analysis, but is key in making the cross-border exchange of information valuable and durable. Focusing on a first limited, yet still valuable, set of data increases feasibility and secures progress.